...court. "The Plaintiff alleges: 1. On or about April 5, 2013, Brad walked into Richard's office and there illegally and feloniously assaulted and battered Richard, thereby causing to Richard great pain and suffering. 2. On or about April 5, 2013, Brad caused Richard to be unlawfully confined in a bound area, causing great physical and emotional suffering on the part of Richard. 3. As a proximate result of Brad's wrongful and unlawful conduct, Richard suffered physical and emotional injuries worth the sum of $200,000. Wherefore, Plaintiff demands that Brad be forced to pay to Richard the sum of $200,000 in compensatory damages, $1,000,000 in punitive damages and any other relief that the court deems just and proper." The complaint is properly captioned, signed and served on Brad. Brad moves to dismiss the action on the ground that the complaint was not specific enough and therefore must be dismissed because it fails to state a claim upon which relief can be granted. Issue According to North Carolina law, was the complaint specific enough to sustain a claim on which relief can be granted? Rule Under North Carolina law, “[a] pleading which sets forth a claim for relief, whether an original claim, counterclaim, crossclaim, or third-party claim shall contain a short and plain statement of the claim sufficiently particular to give the court and the parties notice of the transactions, occurrences, or series of transactions or occurrences, intended to be proved showing...
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... | | | E nterprising, hard-working and technically skilled accounts payable specialist known for accuracy, attention to detail and timeliness in managing disbursement functions for diverse-industry employers. A/P career spans 17 years of experience in manufacturing, retail, higher education and other industries and has included accountability for the processing of up to 20,000 invoices ($1M) per month. Backed by solid credentials (BS in accounting) and proficiencies in generally accepted accounting practices as well as MS Office Suite, Great Plains software, QuickBooks, ERP/EDI systems and SAP. See CareerOne’s advice articles, videos and resume building tool here | | |Key Skills | | | |Accounts Payable Processes & Management |ERP, EDI & Financial System Technologies | |Invoices/Expense...
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...Tanishq: Positioning to Capture the Indian Woman's Heart I. Case Summary: The case study here provides us with the insight of how Tanishq has adopted different strategies to position itself as a mainstream jewelry brand and differentiate itself from the competitors, in the Indian jewelry market. GoldPlus, on the other hand which was launched nine years after Tanishq had entered the jewelry market, is also a subsidiary of the same holding company, which is targeted towards serving the customers which Tanishq was not serving, plain wedding jewelry in rural and semi -urban market. Tanishq, first started as a brand name for jewelry watch of Titan, was targeted towards the Indian high end customers. By then it was positioned as an ego satisfier. The reason for failure of Tanishq in the initial phase was that the company followed a selling concept. They made the product first and then tried to sell it. The consumer preference was not considered while designing the 18 karat jewelry. Over time Tanishq has undergone through a lot of changes in its marketing policies and strategies to position itself as a mainstream jewelry firm rather than targeting a small customers of the whole jewelry market. Tanishq, established in 1995, challenged the established family jeweler and introduced new rules in precious jewelry. Tanishq spread awareness to the public about alleged impurity in Gold jewelry across India. Tanishq introduced innovations like Karat meter, the only non-destructive means to...
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...e- Book Series Guide to Writing a Killer Marketing Plan Written by: Steven Fisher Purpose of this book You are either someone that has been doing marketing as a part of your professional career or you look at as that “thing you do to promote your business and attract customers to buy”. Regardless of where you are along that spectrum, you have arrived here because you have been charged by the CEO of the startup you work for to write a marketing plan for your business or you need to create one for your own business. You need to not just write just any marketing plan. You need to write a Killer Marketing Plan. One that your boss will say “awesome, let’s get started” and which will tell all those people who have been looking for a product or service like yours for a long time. This book is written for you. Marketing plans are sexy mistresses that tempt you to include all of the coolest of campaign ideas without the sanity of budgetary constraints. While marketing is one of the more important functions of a small business, it is one that is limited by the budgets of that business and campaigns must demonstrate a return in order to justify their existence. Since I have written more marketing plans than I care to tell you, I can share with you my knowledge and experience of what has worked almost all the time, some of the time and none of the time. While this is not the single tome on marketing plans, I hope that this helps you balance the unlimited creative...
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...Develop an educational project that includes a specific outcome while teaching academic skills Make Your Own Project-Based Lesson Plan Gloria J. Edwards Educator and Curriculum Development Specialist Unlimited Learning, Inc. Copyright 2002 Mountain Plains Distance Learning Partnership Integrated Learning http://www.integratelearning.org Special funding provided by the U.S. Department of Education, Star Schools. Instructions based on the five-concept template created by Leecy Wise for Star School teachers, Cortez, CO, 2001-2002 Topic: Make Your Own Project-Based Lesson Plan Develop an educational project that includes a specific outcome while teaching academic skills. Identify Grade level or Group Here An integrated lesson plan covering # sessions of approximately # hours each. Your Name as Lesson Author Here The following passage is included in all Integrated Learning lesson plans: Lesson-Planning Approach Students do not learn from what you do, but from what you have them do. This is a template for creating project-based lessons. Examples and important information are set in text boxes, while the rest of the text can be used as lesson template. Text and headings that are part of the “Integrated Learning” lesson format are printed in color bands or bold text. For other examples of our project-based lesson plans, refer to our website www.integratelearning.org . Some learners perceive their “world” as a whole, where all things are interconnected and dependent...
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...Comparative Literature August 2011 semester Description The module will examine the binary categories ‘modern’/‘traditional’ (and/or the ‘primitive’) as they appear in modernising societies. First, we look at representative literature from (what was until recently known as) Great Britain. The question is: why did the world’s homeland of the Industrial Revolution have a fascination with adventure, feats of derring-do and the primitive? We look at a young reader’s Victorian adventure novel, the long-enduring The Coral Island, and the later short stories of Rudyard Kipling (the ‘Bard’ of Empire), and examine the (contradictory?) lure of the primitive, even as British modernity is taken for granted. Second, the module will proceed to examine some major Chinese and Japanese writers and intellectuals (and an Indian poet and critics, the Nobel Prize-winning Rabindranath Tagore) and see how northeast Asian culture was broadly affected by their sense of Western modern superiority in technology, political organisation and literary (and other forms of creative) culture. Both China and Japan, the major countries in East-Southeast Asia, were never colonised, but they were intimidated by the presence of the Great Western Powers (and their colonies) in the region. Japan after the Meiji Restoration (1868) became the first modern Asian nation-state, and their attempts at intensive (and disruptive) modernisation of their culture had a profound impact on the whole region – and this desire to...
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...ECOTOURISM AS PERSPECTIVE WAY OF PERM REGION CULTURAL AND ECONOMIC DEVELOPMENT Aleksandra Dyldina, Anna Pleshkova Perm State National Research University, Perm, Russia 2013 was declared as the Year of Environment in Russian Federation. In Russia there are more than 3 000 of reserves and other specially protected natural areas (SPNA). [1] Recall that the SPNA is land parcel, water lot airspace segment over them, where natural complexes and objects that have special natural protection, scientific, cultural, esthetic, recreational and improving value, that are withdraw by public authorities decision fully or partly from practical use and for that the mode of special protection is established. [2] It is worth to say that the "special protection" should not mean "closed to the people." Therefore it is necessary to solve the problem of people’ environmental education with the development of the regional economy. This problem can be solved by ecotourism as the rapidly developing service. Tourism – one of the sectors of the economy, particularly useful for people. It enables a person to relax, satisfy their natural need and it does not lead to the depletion of natural resources. Ecotourism is responsible travel to natural areas that conserves the environment and improves the well-being of local people. [3] Ecotourism – tourism, including travel to places with relatively untouched nature, in order to get an idea of natural, cultural and ethnographic features of the...
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...Piper Arctic National Wildlife Refuge (ANWR) is a 19 million acre area that lies in the northeast corner of Alaska. The Coastal Plain area, comprising 1.5 million acres on the northern edge of ANWR, is bordered on the north by the Beaufort Sea, on the east by the U.S. Canadian border, and on the west by the Canning River. The Coastal Plain of ANWR is being considered for oil and gas development since it potentially holds billions of barrels of recoverable oil and trillions of cubic feet of recoverable gas. Of the 1.5 million acres of the Coastal Plain, less than 2000 acres would be affected by development. However, because it is an important wildlife habitat, some are concerned that development would hurt the land, endanger wildlife, and not recover enough oil to make the effort worthwhile. ANWR is about the size of South Carolina, and the proposed development area in the Coastal Plain is about one-fifth the size of Washington, DC’s Dulles International Airport. Although ANWR could produce greater than a million barrels of oil per day, more than enough to replace U.S. imports from Iraq, we have to look at the potential social, economic and ecological benefits and consequences to exploring/drilling in ANWR. Environmentalists want to protect ANWR from any drilling because of its environmental and ecological value. They believe that there is too great a danger to the refuge, which is home too many species of birds and fish as well as both land and marine mammals. Environmentalists...
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...Geog 2RC3- Physiographic regions- Jan 10/14 Interior Plains- p.38-39 20 % of Canada’s land mass Sedimentary rocks Low relief Elevation increases from east to west Hudson Bay Lowlands- p- 39-41 3.5 % of landmass Low lying, poorly drained landscape (muskeg) Underlain by sedimentary rocks Arctic Lands- 41-42 Archipelago 10 % of Canada’s landmass Pre-Cambrian crystalline (igneous) rock overlain by Paleozoic sedimentary rock Ellesmere Island Appalachian Uplands- p.42 2% of Canada’s land mass Very old, heavily eroded mountains (Taconic mountains) Geologically complex (sedimentary, igneous, and metamorphic rocks, as a result of 2 periods of orogenesis (440 million years ago to 350 million years ago) Great Lakes-St Lawrence Lowlands- p 42-44 Less than 2% of landmass (1.8%) Smallest- 110 000 sq km 60% of all Canadians live here Underlain by Paleozoic sedimentary rocks Summary Given Canada’s enormous size- considerable variation in physical environment All of Canadian landscape influenced by glaciation Links between physical and human geographies Next- the Niagara Escarpment The Niagara Escarpment Dominant physiographic landform feature in Great Lakes-St Lawrence Lowlands Designated as a UNESCO World Biosphere Reserve in 1990 (12 total in Canada) 1st large scale environmental land use plan in Canada (The Niagara Escarpment Plan) Formation in 2 stages 1. Deposition of sediments by eperic (seas during Ordovician (435-400...
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...Table of Contents Soerangin 1 Personal Skills, Quality and Experience 1 Description of Rangin 2 The product 2 New Rangin Concept 2 The Stall Concept 2 Target Customer 2 Competition 3 Sales and Marketing 3 Start up expenses 3 Financial Scheme 4 Risk 4 Company progress 4 Conclusion 4 Soerangin “No longer plain” Executive summary Rangin is traditional snack from east java; Indonesia the taste is savory with grated coconut inside. The new concept of Sorangin is combining the original plain rangin with variety of flavors Indonesian ice cream “es puter” and diver topping. The marketing mix and sales strategies would make this business profitable, with the financial scheme that attractive to the investor, soerangin would be the leader in the market and breakeven in less tha one and half year. Personal Skills, Quality and Experience In order to open and develop Rangin stall, there are some personal skill that needed to be prepared. Since the plan is going to be food, so the very basic technical skill is cooking skill, but there are also developing skill to bring the business go global such as conducting market research, developing marketing strategies, website designing, motivating employees, communication, legal knowledge, costing, pricing, and selling. Currently I am lack of technical skill such as cooking rangin but with some business competition experience and knowledge that I got from high school and university such as basic marketing,...
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...employers, coworkers, guidance counselors List all 5 here: _____________________________ _____________________________ _____________________________ _____________________________ ____________________________ Summary 6-8 sentences No clichés or grammatical errors Supported by examples of relevant work experience Compelling case for why student is a great hire Experience Picture Full, description of each role All relevant experiences are listed Skills 4-6 skills listed Skills are consistent with student’s brand Education College Partner and Year Up are listed Degrees, dates attended, activities, and awards included Groups Recommendations 2 recommendations listed (YU staff member, mentor, or co-worker (above intern level)) List 2 of the people who have recommended you here: _____________________________ ____________________________ Connections Photo is a professional – looking “head shot” of just the shoulders and head Photo conveys warmth and friendliness, and hopefully, a smile! There is no one else in the photo Photo is not blurry or hard to see Professional attire is worn in the photo Photo has a plain background that does not distract from the rest of the picture Joined “Year Up Alumni – for graduates and supporters” Group Following internship company and 2 other potential employer List the 2 potential employer groups...
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...ASSIGNMENT COVER SHEET UNIVERSITY OFSUNDERLAND BA (HONS) BUSINESS MANAGEMENT Student ID: 139146431/1 | Student Name: PHAN KHOI KHOI | Module Code: MKT_ 306 | Module Name / Title: Marketing Strategy | Centre / College: UTE Ho Chi Minh, Vietnam | Due Date: 10 October 2014 | Hand in Date: 10 October 2014 | Assignment Title: DEVELOPING MARKETING STRATEGY FOR ACB’s CREDIT IN VIETNAM MARKET | Students Signature: (you must sign this declaring that it is all your own work and all sources of information have been referenced)PHAN KHOI KHOI | Marketing Strategy MKT – 306 Assignment Guide – 2014 -15 Module Leader: Karen Wharton Email: Karen.wharton@sunderland.ac.uk Please read all instructions and information carefully. You are required to submit your work under the University Infringement of Assessment Regulations. Your assignment must be submitted to your Study Centre in hard copy with an accurately and clearly completed Assignment Cover Sheet, and an electronic copy on CD in an envelope [hole punched or safely secured into your plastic file or assignment wallet]. Please do not include a plastic CD case/box and remember to write your student code and assignment code clearly onto the disc and envelope. All your assignments must be submitted in conjunction with a Turnitin© report (only if your centre provides the facility). You will need to achieve an overall mark of 40% in order to successfully complete this module. Karen Wharton Module...
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...individualism, new religious sects, abolitionism, and women’s rights change American culture during the antebellum period (1820-1860)? Chapter 11: Religion and Reform 1800-1860 Individualism: The Ethic of the Middle Class Discuss the differing opinions on the lack of rigid class structures in America: Alexis de Tocqueville: Ralph Waldo Emerson: Transcendentalism: How did Second Great Awakening preachers like Finney adopt portion of Emerson’s philosophies regarding man? How did the main teachings of Transcendentalism differ from the teachings of most Protestant faiths of the time? Emerson’s Literary Influence (For each author describe their main literary focus and delineate between fiction or nonfiction) Henry David Thoreau: Margaret Fuller: Walt Whitman: Nathaniel Hawthorne: Herman Melville: Rural Communalism and Urban Popular Culture Utopias: Communalists: Shakers: marriage? Socialism: property ownership? Humphrey Noyes and Oneida: perfectionism: marriage? Joseph Smith: Mormonism: What was summary of Book of Mormon? How were Mormons accepted by those outside of their faith and what did this lead them to do? Brigham Young: Abolitionism -Skip (We will cover this in class) The Women’s Rights Movement Women became involved in what aspects of public life? What was meant by the statement that women belonged in a “separate sphere” from men? What role did women play in improved...
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...Explore 1 Teacher’s Guide John Pallister Contents Introduction to the series .................................................... 2 Introduction to Explore 1 ..................................................... 4 Chapter 1: What is geography? ........................................... 7 Chapter 2: Geographical Skills ........................................... 11 Chapter 3: Our Earth ......................................................... 15 Chapter 4: Atmosphere and weather ................................. 19 Chapter 5: Our World—the main features of the Earth’s surface ................................................. 25 Chapter 6: Asia—our region of the world .......................... 29 Chapter 7: Pakistan—our homeland.................................. 34 Chapter 8: Pakistan—economic activities ......................... 40 Introduction to the series Explore is a new, up-to-date geography series for secondary classes 6–8. The series covers all the geographical topics and learning competencies from the Pakistan National Curriculum for Geography. Guided by the structure of the Curriculum, from Book 1 to Book 3 the focus gradually switches from local (including the geography of Pakistan) to global (world issues such as forest clearances, population and big city growth, and globalization). However, this is done not by simply following the exact sequence of the written curriculum, but by identifying and developing particular topics and themes...
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...Tobacco Control Policy 1/25/15 To: The Honorable Sylvia Mathews Burwell Office held: Cabinet Secretary Department of Health and Human Services From: Date: January 26, 2015 Re: Tobacco Control Policy: Use of Plain Packets for Cigarette The purpose of this memo is to propose a tobacco control policy. The health policy is expected to contribute towards prevention of notable effects resulting from tobacco use, especially smoking through reinforcing public awareness on the effects of cigarette smoking. Recommendations on policy implementation will also be offered. Summary/ Problem Statement Tobacco use, especially smoking has been attributed ample health conditions. World Health Organization identifies tobacco use as a core concern for public health, being one of the enormous threats to public health in the world. Despite the existence of public awareness programs, tobacco use continues to impact on our society economically, socially, and health wise. Therefore, it is time to introduce a more appropriate approach of passing the message to the peoplethat will complement the existing policies. The policy deals with cigarette packaging, where advertising images should be removed from cigarette packets and replaced with images passing health messages. Discussion Currently, cigarette manufacturers use the cigarette packet for advertisement, brand promotion, and some section for health message. Arguably, the health...
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